NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Historic environment

Key objective of NPF4: To support the understanding, protection and importance of the historic environment so that the cultural, social, environmental and economic value of our heritage continues to contribute to Scotland's wellbeing.

A small number of highly detailed responses addressed the care and protection of the historic environment. All responses are available to the relevant Scottish Government policy team and all organisational responses are amongst those available on the Scottish Government's website. This summary focuses on the key points raised across the range of submissions.

The historic environment's contribution to Scotland's sense of national identity and wellbeing was highlighted, including as acknowledged in Historic Environment Scotland's Our Place in Time[25] strategy document. It was also noted that the historic environment forms a core part of Scotland's tourism offer. Others highlighted that the historic environment contributes to a number of wider policy priorities, including by:

  • Making a positive contribution to mitigating the climate change emergency through good management of resources.
  • Providing economic stimulus locally through the skills and knowledge required for good stewardship.
  • The creation of places which are vibrant and empowering to work in, live in, and visit.

Given these connections, there were calls for historic environment policy to be mainstreamed within planning policy. A number of respondents noted their general support for current policy approaches and there was also a suggestion that NPF4 policy on managing the historic environment should be aligned with Historic Environment Scotland's Historic Environment Policy for Scotland,[26] including by adopting the language and terminology used.

It was also suggested that NPF4 should enable planning authorities to access the Historic Environment Records, along with the expertise to understand and utilise the information at a local level.

In line with the suggestions above around recognising the contribution the historic environment plays, it was also suggested that the following should be considered when developing NPF4:

  • Integrating the spatial elements of the current approach into NPF4. It was suggested that the relevant elements of the current SPP should be carried over, and strengthened where needed.
  • PAN 2/2011 should be retained but there is an opportunity to make it more robust and fit-for-purpose. PAN 2/2011 was reported as including important guidance relevant to archaeology, but there was a suggestion that it could be revised, for example to incorporate the idea of 'archaeological value'. In relation to the management of battlefield sites, it was suggested that paragraphs 140,150 and 155 of SPP are appropriate and should be retained.
  • In relation to scheduled monuments, some of the terminology can be open to interpretation, for example, 'integrity of setting' and 'exceptional circumstances'. This should be reviewed, to improve clarity and avoid conflicting interpretations.
  • Conservation objectives should be developed for historic battlefields and gardens and designed landscapes.
  • The preservation of the pre-1919 housing stock, including the stock of tenements, should be addressed as it defines the character of many towns and cities in Scotland.

There was a call for policy to require owners of heritage assets to create stewardship plans with the associated budgets. It was suggested that this would help in identifying where conservation is economically viable and is an issue that should be acknowledged and addressed, for example, if climate change-related retrofitting is required.

Other comments addressed development or adaptation, including in relation to listed buildings, and included that:

  • Current wording makes it difficult for a planning application to be fully compliant and that all options should be considered to allow the continued use, or reuse, of a listed building.
  • Incentives could be devised to encourage more inventive adaptation of historic buildings, for example to embed carbon.
  • Further guidance on enablement, with examples, would be helpful. It was suggested that a new enabling policy should be consistent with the principles and policies contained within the Historic Environment Policy for Scotland. Detailed comments and suggestions on improvements on the topic of enablement can be found in the relevant submissions.
  • Specific guidance is needed in relation to development on the edge of historic towns - this is not addressed sufficiently at present.



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